Finding Text
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Opioid STR Assistance Listing Number: 93.788 Federal Award Identification Number and Year: 167552 - 2024 Pass-Through Agency: Oregon Health Authority Pass-Through Number(s): 167552 Award Period: January 4, 2021, through September 29, 2024 Type of Finding: Material Weakness in Internal Controls over Compliance and Material Noncompliance: Procurement, Suspension and Debarment Criteria or specific requirement: 2 CFR Part 200 sections 200.214 and 200.318-327 outlines the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred. Condition: The Alliance does not have formal procurement or suspension and debarment policy. For the sampled procurement transactions, documentation was not retained supporting the determination that the vendors were single source providers, as required by Uniform Guidance. In addition, a suspension and debarment check was not performed before entering into the covered transaction. Questioned costs: Yes Known: $9,239 Likely: $39,740 Context: The Organization does not have written procurement policies nor suspension and debarment policies. CLA tested six procurement transactions charged to the major program. For the sampled procurement transactions, documentation was not retained detailing the history of the procurement, including: the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Documentation should be retained to evidence the adequate number of price comparisons, price analyses, and rationale of acquisition, including to limit competition where competition is limited or contractor is single source. In addition, five covered transactions were tested for suspension and debarment. Documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions. Cause: Due to a lack of knowledge about federal procurement, suspension and debarment, and documentation requirements. Effect: There is an increased possibility of entering into a covered transaction with vendors/contractors who are federally suspended or debarred. Without adequate records retained, the Alliance is at risk of noncompliance with federal suspension and debarment requirements. Repeat Finding: No Recommendation: CLA recommends the Alliance to develop the procurement policy compliance in with Uniform Guidance, including such documentation as the procurement threshold of the transaction, price comparisons and analyses made, bids obtained, proof of any limited competition, dated vendor screenings and signed authorization of the appropriate program personnel. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within the Alliance. The Alliance also needs to ensure that the policy includes suspension, and debarment checks, and it should be done prior to entering into the program. Each type of disbursement that leaves the Alliance (check, ACH, EFT, credit card, etc.) to improve documentary evidence that costs are being reviewed and approved for appropriateness. Views of responsible officials: There is no disagreement with the audit finding.